July

22, 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey

Ave., SE Washington, DC 20590 Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations Dear Madam, Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, CME Engineering LP (“ CME ”), an operator of the eBee Unmanned Aircraft System (“eBee”) seeks an ex emption from the Federal Aviation Regulations (“FARs”) listed below:

 14 C.F.R. 21  14 C.F.R. 45.23  14 C.F.R . 45.29  14 C.F.R. 61.3  14 C.F.R. 61.113(a) & (b)  14 C.F.R. 61.133(a)  14 C.F.R. 91.7(b)  14 C.F.R. 91.9(b)(2)  14 C.F.R. 91.109(a)  14 C.F.R. 91.119  14 C.F.R. 91.121  14 C.F.R. 91.151(a)  14 C.F.R. 91.203(a) & (b)  14 C.F.R. 91.319(a)(1)  14 C . F . R . Subpart E (91.401 - 91.417) The requested exemption would authorize commercial operations using the eBee for mapping and survey a pplications. These operations will be subject to strict operating requirements defined in the eBee user manual (CME requests the FAA treat the eBee training program as proprietary under 14 C.F.R. 11.35(b) and does not include this document in the public docket) and conditions defined by

the Safety

C ode of the Academy

o f Model Aeronautics (see Annex B), in order to ensure at least an equivalent level of safety to currently

a uthorized operations using manned aircrafts. The eBee will be operated by an individual who fulfill the following requirements:

 Has succ essfully

p assed a manufacturer’s training program for the eBee and the written test of the Recreational or Sport Pilots Li cense ; CME requests the FAA treat the eBeetraining program as proprietary under 14 C.F.R. 11.35(b) and does not include this document in the public docket. **1. CHARACTERISTICS OF THE AIRCRAFT** The eBee is a small (37.8 inches wingspan) and ultra- light (maximum take - off weight of 1.7 pounds) platform made of flexible foam that performs pre -programmed precision aerial mapping missions thanks to the on-board GPS and the related flight management software (eMotion) that allows the operator to plan safely and efficiently

a mission in 3D, and then monitor it in real -time. Thanks to the embedded camera, protected by a f oam envelope, the eBe e takes a collection of high- definition still images that are used later to generate maps and contour lines of the surveyed area. The four main characteristics of the eBee are: a. Very light weight The eBee is so light that the operator can launch it by hand and let it land on almost any surface without requiring a parachute or landing net (belly land). It s low impact energy ( 38 J in case of a controlled emergency

l anding) also significantly reduces the risk of hazardous situations. Finally, the wings of the eBee are detachable and made of flexible foam with no sharp or hard edges and almost no internal strengthening structure. b. Electric -powered The eBee is electric powered. A brushless engine technology makes it silent and reliable. The propeller is attached with a rubber band to the body o f the plane so that it can easily flex away in case of contact with any

object. c. Semi - automatic flight The artificial intelligence incorporated within the eBee autopilot system continuously analy zes data from the Inertial Measurement Unit and from the onboard GPS and takes care of all the aspects of the flight under the supervision of the operator. d. Option for Manual control Additionally, the eBee provides an override capability that allows the operator to take manual actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend automated operations and take manual control of the aircraft should it become necessary to respond emergent circumstances, thanks to the remote controller provided with the system. **2. APPLICATIONS**The eBee will be used to map for natural resources, endangered species and plant life,

topography, as -built construction conditions and progress, quarry and mining operations (noncongested areas).

**3. APPLICABLE LEGAL**  **STANDARD UNDER**  **SECTION 333**  a. Airworthiness assessment of the eBee CME notes that the airworthiness of the eBee has already been demonstrated for different projects in the United States, involving state/federal agencies or universities (among others the New Mexico State University: https://newscenter.nmsu.edu/Articles/view/10208/nmsu-uas - flight-testcenter- conducts - ebee - airworthiness - assessment , and the USACE New Orleans, who coordinated with the Department of Army and the FAA to obtain all authorizations required in order to operate the eBee UAS). Moreover, SenseFly

obtained flight approvals for the eBee (delivered by national civil aviation authorities) in many

countries, among others:

 Switzerland (flight approval for VLOS operation s)  Canada (flight approval for VLOS operations)  Australia (flight approval for VLOS operations)  France (flight approval for Extended-VLOS operations)  Germany

(flight approval for VLOS operations)  United Kingdom (flight approval for VLOS operations)  Norway (flight approval for VLOS operations)  Sweden (flight approval for VLOS operations)  Denmark (flight approval for VLOS operations) b. Operating requirements Grant of the exemption to CME for the eBee will be subject to the following operating conditions, based on the operating conditions set forth by the Academy

of Model Aeronautics (see Annex B). The main restrictions are summarized below:

 Operations to be conducted over private, controlled- access, or public property where approved;  Permission from the land owner/authority required before commencing any flight;  Operations over congested areas shall be avoided;  Operations must not interfere with manned aircraft operations, must yi eld the right of way to manned aircraft, and operators must See & Avoid other aircraft and obstacles at all times Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight

hours  Aircraft operations must remain within Visual Line of Sight (VLOS) and will be visually monitored at all times;  VLOS guaranteed with a GPS geo - fence around operator of 0.5 miles  Flight ceiling pre -programed at 400 feet;  All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with the airport authority, or air traffic control when a control tower is present at the airport;  All operations shall comply with required permissions and permits established by territorial, state, county

o r city j urisdictions; including local law enforcement, fire, or other appropriate governmental agencies.  The eBee operations will be compliant with existing safety procedures inherent to the activities of the related company. c. Operator Requirements The eBee operator will have successfully c ompleted the written test of the Recreational or Sport Pilot Certification**. CONCLUSION**  CME Engineering LP is a Civil , Mining, and Environmental Engineering firm and the use of the eBee’s technology

will make our work more profitable, efficient and will enable us to deliver accurate results in near real time to our clients. This accuracy and time saving ability

will allow the clients to make on-time decisions. The eBee is safer than having CME’s employees out in the fi eld for specific projects, and also very safe for other aircrafts because of the mission specifications (below 400 ft.) and eBee integrated safety features. We are prepared to modify or amend any

part of this request to satisfy the need for an equivalent level of safety . We look forward to working with your office. Please contact us at any time if you require additional information or clarification. Very truly yours, CME Engineering LP, a Pennsylvania limited partnership By: CME Management LLC, its sole general partner By : Joseph W. Lloyd Senior Project Manager / Survey Manager